Non-Commercial nature of LPFM:Can LPFM Stations Run "Barter Ads"?
I am the manager of an internet radio service called Global Community Radio. I make this service and its programming available free of charge to LPFM stations to use when they are not running locla programming. I have some knowledge of the FCC regulations regarding advertising and LPFM, but I need clarification on this issue. GCR airs various syndicated programs from many different sources. One of our music shows wants to be able to air "barter ads" to raise revenue to cover the costs of producing their program. Basically, this music show, "Radio Serena" is a music variety program produced in the style of a commercial radio show, but which airs on noncommercial LPRM stations. The host has recurring expenses for the show such as paying for voice talent and imaging produciton. The host and I have gone around and around about airing barter ads to offset her production costs. I insist that LPFM stations cannot run barter ads because those ads sitll meet the FCC's definition of a "commercial", and any LPFM station running said ads could be subject to fines, or other legal penalties. She argues that because the radio stations airing her show are not actually being paid for running the ads, these ads do not violate any FCC regulations. She also claims that she can find nothing in the FCC regulations concerning noncommercial broadcasting which specifically prohibits the airing of "barter" advertising. While I sympathize with this program's host and her need to generate a bit of revenue to cover her costs, I am not going to knowingly and willfully put LPFM stations using my service in a situation where they may face fines or other penalties from the FCC. If anyone can provide some insight into this matter, it would be very much appreciated.

LPFM Operation:The LPFM public file contains fewer items than regular NCE-FM radio stations. Biennial ownership reports are usually kept in the public file but are not on the list of required items for an LPFM public file. Are LPFM operators required to file ownership reports (FCC form 323E)?